Justia Arbitration & Mediation Opinion Summaries

In this case, the defendant, Bobby Quinton Gentile, pleaded guilty to conspiracy to possess with intent to distribute at least 500 grams of methamphetamine. He later appealed his sentence, arguing that the district court judge improperly coerced him into withdrawing his objections to the drug amount calculation in the Presentence Investigation Report by threatening to deny him his acceptance of responsibility points. The United States Court of Appeals for the Fifth Circuit found no plain error and affirmed the district court's decision. The court held that Gentile's argument that he was judicially coerced to withdraw his objections to the drug amount calculation fails under plain error review because, even assuming arguendo that the district court erred clearly by coercing him, Gentile did not show the error affected his substantial rights. His sentence was affirmed. View "USA v. Gentile" on Justia Law

In a wrongful death action against an assisted-living facility, the Supreme Court of Tennessee held that the claims were subject to arbitration as per an agreement signed by the deceased's attorney-in-fact. The court clarified two key points. First, signing an optional arbitration agreement is not a "health care decision" under the Durable Power of Attorney for Health Care Act. Second, the attorney-in-fact had the authority to sign the arbitration agreement on the deceased's behalf, considering the durable power of attorney gave her the power to act for him in "all claims and litigation matters". The court further ruled that the deceased's son, who brought the wrongful death action, was bound by the arbitration agreement because his claims were derivative of his father's. Consequently, the court reversed the decision of the Court of Appeals and remanded the case to the trial court.In the case, Granville Williams, Jr. died while residing at an assisted-living facility run by Smyrna Residential, LLC. His son James Williams filed a wrongful death action against the facility. The decedent's daughter, acting as his attorney-in-fact under a power of attorney, had signed an arbitration agreement with the facility at the time of his admission. The arbitration agreement was not a condition of admission to the facility. The key issues were whether the attorney-in-fact had the authority to sign the arbitration agreement and whether the son, who was not a party to the agreement, was nevertheless bound by it. View "Williams v. Smyrna Residential, LLC" on Justia Law

This case involves a group of plaintiffs who were minors at the time their guardians purchased and activated DNA test kits from Ancestry.com. The plaintiffs, through their guardians, provided their DNA samples to Ancestry.com for genetic testing and analysis. The plaintiffs later sued Ancestry.com, alleging that the company violated their privacy rights by disclosing their confidential genetic information to another business. Ancestry.com moved to compel arbitration based on a clause in its Terms & Conditions agreement, which the plaintiffs' guardians had agreed to when they purchased and activated the test kits.The United States Court of Appeals for the Seventh Circuit, applying Illinois law, held that the plaintiffs were not bound to arbitrate their claims under the agreement between their guardians and Ancestry.com. The court reasoned that the plaintiffs neither signed the agreement nor created Ancestry.com accounts, and did not independently engage with Ancestry.com's services. Furthermore, the court refused to bind the plaintiffs to the agreement based on equitable principles, including the doctrine of direct benefits estoppel. The court noted that while the plaintiffs theoretically could benefit from Ancestry.com's services, there were no allegations that the plaintiffs had actually accessed their DNA test results.The court therefore affirmed the district court's decision denying Ancestry.com's motion to compel arbitration. The court's holding clarified that under Illinois law, a minor cannot be bound to an arbitration agreement that their guardian agreed to on their behalf, unless the minor independently engaged with the services provided under the agreement or directly benefited from the agreement. View "Coatney v. Ancestry.com DNA, LLC" on Justia Law

Shawn Fowler, a former Montana state trooper, sued the Department of Justice, Montana Highway Patrol (MHP) alleging constructive discharge in violation of the Wrongful Discharge from Employment Act (WDEA). He also alleged breach of contract by the Montana Public Employees Association (MPEA) for declining his request to arbitrate. Fowler claimed that he was forced to retire due to a hostile work environment, which was mainly due to disciplinary action taken against him for mishandling two suspected DUI traffic stops in 2017. The MHP argued that Fowler, who was covered by a collective bargaining agreement (CBA), failed to exhaust the grievance procedures of the CBA before filing a lawsuit.The Supreme Court of the State of Montana reversed the judgment of the Sixth Judicial District Court, Park County. The Supreme Court held that an employee covered by a CBA can't bring a claim under the WDEA. The Court determined that Fowler’s alleged constructive discharge was covered by the CBA and he was required to exhaust the grievance procedures for a constructive discharge through the CBA. The Court found that Fowler did not grieve any of the events preceding his suspension, which he claimed contributed to his constructive discharge, and he resigned from employment prior to exhausting the grievance procedure of the CBA. The Court concluded that the District Court erred in denying the State’s two motions for summary judgment and reversed the judgment. View "Fowler v. Department of Justice" on Justia Law

In a dispute between SmartSky Networks, LLC and DAG Wireless, Ltd., DAG Wireless USA, LLC, Laslo Gross, Susan Gross, Wireless Systems Solutions, LLC, and David D. Gross over alleged breach of contract, trade secret misappropriation, and deceptive trade practices, the United States Court of Appeals for the Fourth Circuit ruled that the district court did not have the jurisdiction to enforce an arbitration award. Initially, the case was stayed by the district court pending arbitration. The arbitration tribunal found in favor of SmartSky and issued an award, which SmartSky sought to enforce in district court. The defendants-appellants argued that, based on the Supreme Court decision in Badgerow v. Walters, the district court lacked subject matter jurisdiction to enforce the arbitration award. The Fourth Circuit agreed, noting that a court must have a basis for subject matter jurisdiction independent from the Federal Arbitration Act (FAA) and apparent on the face of the application to enforce or vacate an arbitration award. The court concluded that the district court did not have an independent basis of subject matter jurisdiction to confirm the arbitration award. As such, the court reversed and remanded the case to the district court for further proceedings. View "Smartsky Networks, LLC v. DAG Wireless, LTD." on Justia Law

The United States Court of Appeals for the Ninth Circuit affirmed the lower court's order to compel arbitration and dismiss without prejudice a series of lawsuits against several sports goods e-commerce companies (the defendants). The lawsuits were brought by several plaintiffs, who were consumers that purchased goods online from the defendants and had their personal information stolen during a data breach on the defendants' websites. The defendants moved to compel arbitration based on the arbitration provision in their terms of use. The appellate court held that the plaintiffs had sufficient notice of the arbitration provision and that the arbitration clause was not invalid under California law, was not unconscionable, and did not prohibit public injunctive relief. Furthermore, the parties agreed to delegate the question of arbitrability to an arbitrator according to the commercial rules and procedures of JAMS, a private alternative dispute resolution provider. View "PATRICK V. RUNNING WAREHOUSE, LLC" on Justia Law

In this putative class action lawsuit, Maria Johnson, a former employee of Lowe's Home Centers, LLC, brought claims on behalf of herself and other Lowe's employees under California's Private Attorneys General Act of 2004 (PAGA) for alleged violations of the California Labor Code. Johnson had signed a pre-dispute employment contract that included an arbitration clause.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision to compel arbitration of Johnson's individual PAGA claim, as a valid arbitration agreement existed and the dispute fell within its scope. However, the district court's dismissal of Johnson's non-individual PAGA claims was vacated. The lower court had based its decision on the U.S. Supreme Court's interpretation of PAGA in Viking River Cruises, Inc. v. Moriana, which was subsequently corrected by the California Supreme Court in Adolph v. Uber Techs., Inc. The state court held that a PAGA plaintiff could arbitrate their individual PAGA claim while also maintaining their non-individual PAGA claims in court. The case was remanded to the district court to apply this interpretation of California law. The Ninth Circuit rejected Lowe's argument that Adolph was inconsistent with Viking River. View "JOHNSON V. LOWE'S HOME CENTERS, LLC" on Justia Law

The Supreme Court of New Jersey examined whether N.J.S.A. 18A:6-16 limits an arbitrator’s authority to penalize conduct under the Tenure Employees Hearing Law (TEHL), N.J.S.A. 18A:6-10 to -18.1. The defendant, the Board of Education for the Town of West New York Public Schools, brought tenure charges against the plaintiff, Amada Sanjuan, for conduct unbecoming. The charges were based on alleged false claims made by Sanjuan about an accident at the school. An arbitrator concluded that Sanjuan's conduct warranted a penalty, but not dismissal. The arbitrator demoted Sanjuan from her tenured administrative position to a tenured teaching role, without backpay. Sanjuan sought to vacate the arbitration award, arguing that the arbitrator exceeded his authority by demoting her. The Appellate Division agreed, interpreting N.J.S.A. 18A:6-16 to allow sustained tenure charges to result only in termination or loss of salary, but not demotion. The Supreme Court of New Jersey reversed, holding that N.J.S.A. 18A:6-16 provides the basis to refer a case to arbitration but does not limit an arbitrator’s authority to impose penalties. Therefore, the Supreme Court reinstated the arbitrator's award demoting Sanjuan. View "Sanjuan v. School District of West New York" on Justia Law

In this case, employers M&K Employee Solutions, LLC and Ohio Magnetics, Inc. withdrew from the IAM National Pension Fund during the 2018 plan year. The Fund assessed withdrawal liability for each entity based on actuarial assumptions. Both employers challenged their respective assessments and won in arbitration, with the arbitrator ruling that the Fund's actuary erred in setting actuarial assumptions for a given measurement date after the measurement date based on information available at that date. The Fund appealed and the district court vacated the arbitration awards, ruling that an actuary may indeed set actuarial assumptions for a given measurement date after the measurement date based on information available "as of" the measurement date.The Court of Appeals for the District of Columbia Circuit affirmed the district court's decision. The court held that it would be contrary to the legislative intent of the Multiemployer Pension Plan Amendments Act to require an actuary to determine what assumptions to use before the close of business on the measurement date. The court also ruled that M&K was entitled to a “free-look” exception because it partially withdrew from the Fund within a period of less than five years, meaning it could withdraw without incurring liability. View "Trustees of the IAM National Pension Fund v. M & K Employee Solutions, LLC" on Justia Law

The case involves a group of former firefighters who retired from the city of Meriden and claimed damages from the city and the Meriden Municipal Pension Board for alleged breach of a collective bargaining agreement. The plaintiffs, who retired in 2015, claimed that they should have received an increase in their pension benefits based on a 2% wage increase that was awarded retroactively in an arbitration process after the plaintiffs had retired. The trial court ruled in favor of the plaintiffs, holding that the defendants had breached the collective bargaining agreement by failing to recalculate the plaintiffs' pension benefits based on the retroactive wage increase.On appeal, the Connecticut Supreme Court reversed the trial court's decision. The Supreme Court held that the defendants did not breach the collective bargaining agreement. This conclusion was based on the fact that the pension plan did not allow for the recalculation of pension benefits for retirees who voluntarily retired before the issuance of the arbitration award. The court noted that the pension plan only allowed for a retroactive adjustment of pension benefits for those who were forced to retire due to reaching the mandatory retirement age of 65. The court also held that the trial court did not lack subject matter jurisdiction to hear the case, rejecting the defendants' claim that the plaintiffs failed to exhaust their administrative remedies before filing the lawsuit. View "Stiegler v. Meriden" on Justia Law